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of <h1>Profits from International Aircraft Operations Taxable Only in Contracting State Under Specific Conditions, Excluding Article 12 Interest.</h1> Profits earned by an enterprise from a Contracting State through operating aircraft in international traffic are taxable only in that State. This rule applies to profits from participation in pools, joint businesses, or international operating agencies. It also applies if the enterprise has an office or agency in the other State, provided the activities are directly related to aircraft operation in international traffic. Interest on funds related to such operations is considered part of the profits and is not subject to Article 12. 'Operation of aircraft' includes air transportation of passengers, mail, livestock, or goods, ticket sales, incidental aircraft leasing, and related activities.
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